2015 American Academy of Neurology

©2015 American Academy of Neurology MACRA and the Axon Registry: What You Need to Know Lyell K. Jones Jr. MD, FAAN Vice Chair, AAN Registry Committe...
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©2015 American Academy of Neurology

MACRA and the Axon Registry: What You Need to Know Lyell K. Jones Jr. MD, FAAN Vice Chair, AAN Registry Committee Associate Professor of Neurology, Mayo Clinic September 8, 2016 ©2015 American Academy of Neurology

Goals • By the end of this session, we want you to be able to explain to a colleague:  The essential aspects of MACRA and its effect on CMS payment systems  Differences between the two major components of MACRA: the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APM)  Interactions between the MACRA and the Axon Registry

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Background: Health Care Costs

Projections of National Health Care Expenditures and Share of GDP, 2013-2023 ©2015 American Academy of Neurology

Source: Kaiser Family Foundation Slide 3

Background: Health Care Costs

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CMS, 2015: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Factsheets/2015-Fact-sheets-items/2015-01-26-3.html Accessed 2/5/15

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Background: Current CMS Programs • Physician Quality Reporting System (PQRS)  Providers who report approved quality measures avoid penalties (up to -2% in 2017)  CMS will be moving to performance based adjustment

• Value-Based Payment Modifier (VBPM)  Providers are scored on PQRS performance and resource use (cost) to receive bonuses or penalties (-4% to +4%)

• Meaningful Use (MU), or EHR Incentive Payment Program  Has transitioned from bonuses for attestation to penalties for failing to attest (-4% in 2017) ©2015 American Academy of Neurology

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What is MACRA? • The Medicare Access and CHIP

Reauthorization Act of 2015 (MACRA) • Passed with wide bipartisan and bicameral support House vote: 392-37 Senate vote: 92-8

• Signed into law April 16, 2015 • Proposed rule released April 2016 ©2015 American Academy of Neurology

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Medicare Payment Modernization • Permanent repeal of the SGR • MACRA implements a completely new payment structure

Volume

Value

• Rulemaking will be critical to implementation ©2015 American Academy of Neurology

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Quality Payment Program

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MIPS Exclusions

First year of Medicare Part B Participation

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Below low volume threshold for patients seen/ Medicare allowable charges

Qualifying participant in an approved advanced Alternative Payment Model (APM) Slide 9

MIPS Performance Categories • Quality • Resource Use • Advancing Care Information • Clinical Practice Improvement Activities

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MIPS Performance Categories Quality (50%) Resource Use (10%)

Advancing Care Information (25%) Clinical Practice Improvement Activities (15%) ©2015 American Academy of Neurology

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MIPS Performance Categories • Quality (50%)  Will closely resemble PQRS  Measures will be selected from multiple domains: –Clinical care –Safety –Care coordination –Patient and caregiver experience –Population health and prevention

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MIPS Performance Categories • Quality (50%)  Certain measure types will be given priority for inclusion: –Outcomes –Patient experience (such as patient reported outcomes or PROs) –Care coordination –Appropriate resource use

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MIPS Performance Categories • Resource Use (10%)  This will be similar to the Value-based Payment Modifier (VBPM)  New “classification codes” will be used: –Care episode groups: likely will be used to identify episodes in episode-based payment models –Patient condition groups: likely will be used for group assignments with condition-based payment –Patient relationship categories: likely will be used to define provider attribution of patient outcomes ©2015 American Academy of Neurology

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MIPS Performance Categories • Advancing Care Information (ACI, formerly Meaningful Use or MU) (25%)  Will generally align with existing MU requirements  Inconsistencies between current programs (e.g., PQRS and MU) will be eliminated  Approved measures (in the Quality category) will automatically satisfy the MU quality measure reporting requirements

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MIPS Performance Categories • Clinical Practice Improvement Activities (CPIAs) (15%)  This is new for CMS, but will feel similar to practice improvement activities in other parts of our practice  Approved CPIAs will likely include: –Expanded practice access –Population health management –Care coordination –Beneficiary engagement –Patient safety and practice assessment –Participation in an APM  QCDR (registry) participation will positively impact score ©2015 American Academy of Neurology

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MIPS Risk Corridor 10.00%

5.00%

0.00% 2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

-5.00%

-10.00%

Combined PQRS, MU, VBPM penalties -15.00% Annual Update

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Max. Penalty

Bonus Potential Slide 17

Alternative Payment Models • Providers that receive significant revenue from qualifying APMs are exempt from MIPS • Eligible for 5% bonus 2019-2024 • Qualifying APMs:  Use certified EMR technology  Employ quality measures similar to MIPS  Must be risk-bearing

• Model criteria to be further defined by CMS ©2015 American Academy of Neurology

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Alternative Payment Models • Current examples of APMs:  Accountable care organizations (ACOs)  Patient-centered medical homes (PCMHs)  “Bundled” payments/episode-based payments

• Advanced APMs described in proposed rule are very narrowly defined  Flexibility and specialty-relevant models will be important to encourage neurologist participation  The AAN is actively developing neurology-relevant APMs ©2015 American Academy of Neurology

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Alternative Payment Models • A Technical Advisory Committee (PTAC) has been formed to advise CMS on development of new APMs  11 members, 7 physicians

• New APMs may be submitted on an ongoing basis • CMS is tasked with developing APMs targeted to:  Specialty practices  Smaller practices  Risk-based models

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Overall Payment Updates 2015-2018 2019

2020

2021

20222024

2025

2026+

0.5%

0%

0%

0%

0%

MIPS: 0.25% APM: 0.75%

MIPS PQRS, MU, -4% to Adjustment and VBPM +4%* Factor penalties in effect (4.5% to 10%+)

-5% to +5%*

-7% to +7%*

-9% to +9%*

-9% to +9%

-9% to +9%

APM Bonus

5%

5%

5%

5%

% Medicare Revenue from APM

25%

25%

50%

50-75%

75%

75%

Conversion Factor Update

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0.5%

*additional bonus for top performers NOT included

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MACRA: Specialities and Subspecialties • While the proposed rule reduced the number of reported quality measures from 9 to 6, there may be few relevant options in a subspecialty practice • Advanced APMs are narrowly defined, with unresolved barriers for specialty practices • Risk adjustment in the proposed rule does not take into account subspecialty patient populations

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How is AAN preparing for MACRA? • The AAN has been very active in the regulatory

advocacy phase, urging CMS to consider neurologists and their patients in the rulemaking process • AAN staff and volunteers are actively working to develop new payment models that better serve neurologists • Using numerous channels (trained speakers, AAN.com, online videos, the Annual Meeting, etc), the AAN is working to educate neurologists on the urgency of approaching payment changes ©2015 American Academy of Neurology

Axon Registry Participation TM

• Will seamlessly report Quality data and ACI attestation in MIPS • Will positively impact score on CPIA component of MIPS • Will give practices access practice trend data and identify potential areas for improvement • Go to www.aan.com/practice/axon-registry for more information ©2015 American Academy of Neurology

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MACRA and the Axon Registry • The rule proposes QCDRs act as intermediaries on behalf of clinicians and submit data for the Quality, CPIA, and ACI categories:  Quality - Means for quality reporting component  Clinical practice improvement activities – Component of several CPIAs and as a means to attest to participation  Advancing care Information- Means for attestation in ACI component

• In the future, align MIPS/Axon measures and further clarify CPIAs ©2015 American Academy of Neurology

MACRA and the Axon Registry • Concerns with the proposed rule:  Little detail in proposed rule on requirements for QCDRs  No guidance for vendors or QCDRs  As CMS further clarifies, AAN will assess AAN’s potential financial impact of providing service and vendor capability to develop the technology

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What do you need to do now? • If you haven’t reported on meaningful use (MU), start now • If you haven’t reported PQRS measures, start now • If you have done PQRS, become familiar with your QRUR reports to identify areas for improvement

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MACRA: Take Away Points • MACRA signals the transition to value-based payment systems • Many details have yet to be clarified in the final MACRA rulemaking • The ideal MACRA participation pathway for any one practice will depend on a number of factors • Axon will be an important tool for neurologists in the MACRA era ©2015 American Academy of Neurology

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Questions?

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Thank you!

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